On December 6, 2014 Bill C-36 "The Protection of Communities and Exploited Persons Act" was put into place by the Conservative government. This was in response to the SCC ruling made in December 2013 in Bedford and Canada to strike down laws pertaining to "Communicating for the purpose of Prostitution", "Operating or being a found-in in a common bawdy house", and, "Living wholly or partly off the avails of prostitution of another person". The SCC ruled that these laws caused endangerment to sex trade workers and was contrary to our Section 7 rights under the Canadian Charter of Rights and Freedoms. The SCC further ruled those laws to be unconstitutional because there was never any law in place in Canada pertaining to the purchase or sale of sexual services. The SCC allowed the Canadian government one year to establish "how and where" prostitution would occur in Canada.

In the Summer of 2014 the Conservative government brought out Bill C-36. The Bill did not dictate "how and where" prostitution would occur but sought to eradicate the profession in its entirety. Conservative Justice Minister Peter MacKay referred to us as victims, our clients as "johns", and, our associates as "pimps". Hearings were held by the Justice Committee and the Senate in which the Conservative government called the majority of the witnesses, (largely Human Trafficking Victims). The testimony of these women was absolutely irrelevant to the cause of the consensual sex trade. A review of the laws was set to occur after five years time, and, the NDP opposition placed an unsuccessful Motion for a review after two years. The Opposition also asked the Conservative government to place the new proposed new law before the SCC for a decision as to its constitutionality, and, the Conservative government refused to do this. A vote was had in the House of Commons with the majority Conservative government voting for this morality based Act, and, the NDP and Liberals voting against it. The majority Conservatives won and the law was put into force on December 6, 2014.

The highlights of the Act are as follows:

- The purchase of sexual services in Canada was outlawed;

- We Sex Trade workers were given the rights to do in-calls;

- Although families of workers, drivers, and, security personnel were legalized, it remained illegal for escort services, and, receptionists and answering services to operate, and/or, make any material gain off of sex work;

- The advertising of "sexual services" in Canada became illegal; Although, no definition of sexual services was ever given.

These new laws are problematic, and, they cause heightened endangerment and risks to sex workers; More so, than the previous laws:

- The clientele base has been compromised and Clients do not want to reveal their identities, and, will not allow the time on public streets to be adequately screened;

- Workers are forced to work independently, and, cannot successfully negotiate adequate pay to hire proper security;

- Respectable avenues for discreet and tasteful advertising will not accept our advertising;

- Receptionists and answering services are branded as "pimps".

Angels Angels believes that in a democratic society there should not be any laws concerning the purchase of sexual services between consenting adults, and, that criminalization should only exist in trafficking cases. The law criminalizing purchase, and, most of Bill C-36 endangers us workers, and is, moreso infringing our Section 7 rights under the Canadian Charter of Rights and Freedoms than the laws previously struck down.

We further believe that the advertising ban, and third party involvement, infringes upon our Section 6 rights as Canadians under the Canadian Charter of Rights and Freedoms "to seek employment, and, gain a livelihood in Canada".